EPA Lead Safety Forms For Painters

The Environmental Protection Agency (EPA) contains a set of standards called the Renovation, Repair, and Painting Rule (RRP) that are designed to protect workers and the general public when work is performed that may disturb lead-based paint (LBP). Two specific forms are explicitly required by the EPA on any residential project and a few other specific instances where the structure to be worked upon was built before 1978. These are the Pamphlet Disclosure Form(s) and the Renovation Recordkeeping Checklist. The Mobile App also includes another form that can be used to document conditions that existed prior to the start of work.

Pamphlet Disclosure Forms

The EPA has created a pamplet titled Renovate Right that must be given to residential dwelling occupants prior to the start of work. This pamplet describes the potential for there to be LBP in or around their dwelling, the hazards LBP presents, the requirements of workers disturbing LBP, and the dwelling occupant’s rights. You can provide the Renovate Right pamphlet in soft or hard copy formats, so long as it is provided prior to the start of work. 

EPA RRP enforcement is on the rise and providing documentation of pamphlet disclosure is one of the first things you will be asked to provide if there is any sort of investigation. Fines for failing to document this pamphlet disclosure start at $5000 per occurance and can be as much as $37,500 PER OCCURANCE!

You are required to collect documentation proving occupants have received this pamphlet, and the Mobile App provides two methods for documenting this disclosure.

EPA RRP Pamphlet Disclosure Form – OCCUPANT SIGNATURE

When an adult dwelling occupant is available to provide a signature, this is the preferred method of documentation. Simply have the dwelling occupant read and sign the form. One signature per dwelling is sufficient. In mulit-unit properties, a signature from each dwelling is required.

EPA RRP Pamphlet Disclosure Form – SELF CERTIFICATION

In some instances, the dwelling occupant may not be available to sign or may refuse to sign. In these instances you are allowed to Self Certify. This basically states that you have made a good faith effort to provide the pamphlet, explain how this was done, and sign the form yourself. This version of the form in the Mobile App includes a camera button so that you can insert a picture of your efforts to provide the pamphlet. For example, sliding the pamphlet under the dwelling door, leaving the pamphlet by the mail boxes, or posting a notice by the main entryway.

Renovation Recordkeeping Checklist

Throughout EPA RRP projects, you are required to completed a Renovation Recordkeeping Checklist. The purpose of this checklist is to ensure that the proper lead-safe work practices are adhered to during the project. Normally, this form is not completed in one sitting – it gets completed throughout the project as the different tasks are performed.

NOTE: two specific fields of this form ask for information on the lead dust sampling technician and the type of test kit used. In almost all instances, it is best NOT to test for lead, but to assume it is lead and simply to take all the appropriate measures. If you are not testing for lead, the contents of these two fields should be filled in as “assumed to be lead”.

Initial Conditions Checklist

While this is not a ‘required’ piece of documentation, it can serve to protect your business. For example, if a compliance officer comes out to one of your job sites and sees LBP chips on the ground, it will be assumed that this contamination of the soil was created by your crew not adhering to the RRP lead-safe work practices. However, if you can show thru pictures that the ground was contaminated this way before you began work, you stand a much better chance of avoiding large fines.

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